Case Brief: House V. Bell (2006)

Case Brief: House v. Bell (2006)

547 U.S. 518, 126 S ct. 2064, 165 L.E.d 2 d 1

Facts: On July 13, 1985 in Luttrell, Tennessee the victim Carolyn Muncey was murder. The defendant Paul House who was also a friend of Carolyn was charged and convicted of the murder based on circumstantial evidence. The evidence that was found put House near where the dead body was found, the victim’s blood was found on House’s pants, and House’s semen was found on the victims clothing.

House was sentenced to the death penalty. In state trial court House filed for a pro se petition for post-conviction relief, the court dismissed the petition. In state court House filed for a second post-conviction petition as an attempt to reassert his ineffective assistance claim, the Tennessee Supreme Court held that House’s claims were barred under state statute. House than also made a claim for habeas corpus explaining that he has received ineffective assistance of counsel and prosecutorial misconduct. During the time that House submitted for habeas corpus he claimed that he had new evidence that proved his innocence. But this petition was also denied because House could not by pass the reasonable juror standard. The reasonable juror standard of view was also established in the case of Schlup v. Delo. Finally in 2002 the United States Court of Appeals of the 6th circuit made a decision to review the new evidence that House claimed to prove his innocence.

The new evidence involved two witnesses reporting a murder confession from Carolyn’s husband; they also reported a history of abuse and violence from the husband towards Carolyn. The new evidence also showed the semen found on Carolyn’s clothing belonged to her husband. The Federal Court of Appeals still rejected House’s appeal in an 5-3 decision. The Tennessee Supreme Court in December 2003 refused to consider new DNA evidence in a death penalty, appeal does not qualify for a new trial. Finally on June 28, 2005, U.S. Supreme Court agreed to take the case and open a new trial due to new evidence presented that claimed House as innocent. Based on the new DNA evidence and witnesses, the husband of Carolyn was found guilty of murder. House’s habeas corpus petition was finally allowed and the new evidence pointing the guilty verdict of Carolyn’s husband, all this allowed for House to be considered not guilty and he then released from prison.

Issues: In regards to House’s habeas corpus claim his claim is to be judged against these two standard court issues; Schlup v. Delo and Herrera v. Collins court cases. How much evidence is required to be presented for House to be proven innocent and for him to also be able to obtain habeas corpus relief?

Rule: Habeas Corpus cannot be granted to a defendant unless the evidence provided by the petitioner is sufficient in the eyes of the court. If the evidence is sufficient enough then there can be another trial which could result in a different outcome in the defendants’ case.